Epstein Secrets

reh (November 17. 201)7) "Cop( flops letting mogul gm off easy' kittpitivww.nyposteorWseven,11122007.'newsinarionalnev.:Ceops_rlops New York Post. Keller. Larry (February 6, 20081. 'Second teen-see sun seeks $50 million from Jeffrey Epstein" (https:hweb.archive.ortmehr200802091315054moRwww.palmbeael

me whose resident had died and the provided tekplione contact information was also not a functioning contact.Ern The woman (now using the pseudonym "Jane Doe') filed a new lawsuit in June 2016. this time in the U.S. District Court for the Southern District of New York. She excluded some of her previous acc

substantiate the claims!" On September 30. 2016. the woman re-filed the lawsuit in New York. with an additional witness identified by the pseudonym "Joan Doe".'"" There was no further information available on the allegations outside the claims made anonymously by the two women. They were not made availabl

FEY,EDWARD G MINIKES,MICHAEL KOLLER,HELMUT BALLINGER,WALTER S SLOTKIN,M

QUINN,OLIVER H LOCKER,NANCY OWEN,JANE D CUSHMAN & WAKEFIELD KELLER,MICHAEL

uture plea deal. He insists Epstein will emerge in the end with his: reputation untarnished. "He will recover from this," he said. Staffwriter Larry. Keller and staff researchers Bridget Bulger, Angelica Cortez, AmyHanaway and Melanie Mend contributed id this'story. [email protected] CA/Aronberg-000149 FI

.powerful, politically connected money manager and simply refused to testify against him. In other cases, they said, the women changed their stories. Jane Doe 2, who is trying to have the non-prpsecution agreement thrown out, initially described Epstein as "an awesome man" arid told prosecutors she hoped “not

ted information only if it "clearly appears" to the court that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Keller Financial Svcs., supra at 399, ciSgr Hoffman at 486. 12 EFTA00067394 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Pag

day of March, 2009. Adam D. Horowitz, Esq. Jack Alan Goldberger Stuart S. Mermelstein Es• Atterbu Goldberger & Weiss P.A. Counsel for Plaintiff Jane Doe #2 ounse or 'e en ant Je rey o- Epstein 14 EFTA00067396 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Page 15 of 15

imony: Civil & Cr'):) al, 6th edition. Charlottesville, Va: Lexis Law Publishing. (532 pages) Articles and Chapters 1968 Fishman, E.F. (Loftus), Keller, L., & Atkinson, R.C. (1968). Massed vs. distributed practice in computerized spelling drills. Journal of Educational Psychology, 59, 290-296. • Re

Balancing with the players stacked against you. Applied Cognitive Psychology, 16, 365-366 (Book Review). Loftus, E.F. & Guyer, M. (2002) Who Abused Jane Doe?: The Hazards of the Single Case History. Skeptical Inquirer. Part I. Vol 26, #3 (May/June), Pp. 24-32. Loftus, E. F. & Guyer, M. J. (2002) Who Abu

easy' initp7www.nyposteonskevea I 1122007nevanationsInewskops flops August 8. 2013. New York Post. I i Weiss. Philip (December 10. 2007) "The 24. Keller. Lamy (February 6, 20081. "Second ieenseic sod seas 550 million Fantasist" rlutpalnynugeomnetedfewureaM1826/k New York. Retrieved from Jeffrey Nov

home whose resident had died and the provided tekphone contact information was also not a functioning contact!" The woman (now using the pseudonym "Jane Doe, filed a new lawsuit in June 2016. this time in the U.S. District Court for the Southern District of New York. She excluded some of her previous acc

e faces 550M sexual assault lawsuit' (Nip:I/news findbw.coniltdoesdocdpi/docepstein2060flemp5.1emly Findlay. Thomson Reuters. February 6.2008. 35. Keller, Larry (Mach 5.2008) Third alleged victim riles sex sun against Wilkey Epstein (htqwdweb.archive.orgAvelv2001103081505001mp:fivewwprilmbeacht I'ai

ome whose resident had died and the provided tekplione contact information was also not a functioning contact.'" The woman (now using the pseudonym "Jane Doe) filed a new lawsuit in June 2016, this time in the U.S. District Court for the Southern District of New York. She excluded some of her previous acc

ffittp:cwww.nyposticom'sevenel 11220073tevninationalnev.:Ocops flops August & 2013. New York POSS. I I Weiss. Philip (December 10. 2007) "The 24. Keller. Lam/ (February 6, 20081. 'Second teen-sex soil seeks 550 million Fantasist' (hrepOrtymageombewdfasuiresJ41826/3 New York. Retrieved from Jeffrey

9/19,rape- lowsu it-against donald•trump•voluntarily -dismissed's Sniper. am. Retrieved November 6, 2016. 49 Lupton. Albeno (September IC, 2016) - 'Jane Doe' Plans to Re-File Sexual Assault Lawsuit Against Trump With 'Additional Witness' " (httpalinvnewz.conthigkprofilebreaking-jane-doe-drops-sexual- ass

nscend any difficulties that the exercise of the privilege may impose on society in the detection and prosecution of a crime." Id, at 490; and In re Keller Financial Svcs. of Fla., Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only extends to answers that would in themselves support a con

ing these protections meaningless in attempting EFTA00222075 Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 2 of 37 Jane Doe No. 2 v. Epstein Page 2 to assert and argue the factual basis for the additional objections and privileges. See part ILA. herein. I. Defendant E

ted information only if it "clearly appears" to the court that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re Keller Financial Svcs., supra at 399, ciSgr Hoffman at 486. 12 EFTA00222536 Case 9:08-cv-80119-KAM Document 65 Entered on FLSD Docket 03/25/2009 Pag

scayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitzehermanlaw.com Iriveraahermanlaw.com Counsel for Plaintiff Jane Doe #2 Jack Alan Goldberger Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300